Privacy Policy

Last updated: May 2013

cleverbridge AG and cleverbridge, Inc. ("cleverbridge") take the privacy and protection of personal information ("Personal Information") very seriously. By visiting the cleverbridge online store ("Store"), cleverbridge web site ("Site") and/or ordering products and services (collectively, "Products") from cleverbridge, you acknowledge that you accept the practices and policies outlined in this Privacy Policy ("Privacy Policy"). Unless otherwise defined herein, capitalized terms shall have the meanings assigned to such terms set forth in the General Terms and Conditions of Sale that you can find at and which incorporates this Privacy Policy by reference.

cleverbridge has been awarded TRUSTe's Privacy Seal signifying that this Privacy Policy and practices have been reviewed by TRUSTe for compliance with TRUSTe's TRUSTed Cloud Program Requirements including transparency, accountability and choice regarding the collection and use of your personal information. TRUSTe's mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our Privacy Policy or practices, please contact us at privacy(at)cleverbridge.com. If you are not satisfied with our response you can contact TRUSTe here.

The TRUSTe program only covers the use and disclosure of information we collect on the Store. The collection and use of information shall be limited to the purpose of ordering products and services.

What This Privacy Policy Covers

This Privacy Policy describes cleverbridge's use of Personal Information and Anonymous Information that we collect when you visit the Store and/or order a Product. This Privacy Policy does not apply to the use of your Personal Information that is collected by third parties that cleverbridge does not own or control or that do not support cleverbridge in providing the Store or Products.

BY VISITING THE STORE, ORDERING PRODUCTS, OR OTHERWISE SUBMITTING PERSONAL INFORMATION THROUGH THE STORE, YOU EXPRESSLY CONSENT TO THE PROCESSING OF YOUR PERSONAL INFORMATION ACCORDING TO THIS PRIVACY POLICY.

cleverbridge, Inc. participates in the Safe Harbor program developed by the US Department of Commerce and the European Union. cleverbridge, Inc. has certified to adhere to the Safe Harbor Privacy Principles agreed upon by the United States and the EU. For more information about the Safe Harbor and to view the cleverbridge certification, visit the U.S. Department of Commerce's Safe Harbor web site.

Types and Use of Information We Collect

In general, Personal Information you submit to us is used by us either for the purpose of registration (if any), to provide you with the Products that you order, process payments, respond to requests that you make, to better tailor the features, performance and support of the Store, and to offer you additional information, opportunities, and functionality. We also use this information to prevent or detect fraud or abuses of our website and enable third parties to carry out technical, logistical or other functions on our behalf.

Here are the types of information we collect as well as their designated use.

Personal Information

"Personal Information" is information that is personally identifiable like names, addresses, email addresses, or phone numbers, as well as other non-public information that is associated with the foregoing.

We collect the following Personal Information that you submit to us voluntarily:

Upon accessing our Site and/or Store, certain additional information is automatically collected and then saved in protocol files (so-called usage data). This information includes, among other things, you Internet Protocol (IP) address. We may use this information for internal purposes, such as determining certain settings for the Store, such as language and location, maintaining our operating ability, preventing fraudulent access to our ordering service or analyzing usage patterns. For more information visit the "Automatic Data Collection and Anonymous Information" section.

In order to purchase Products through the Store, you have to provide (and we will collect) your name, address, email address, and all the financial information necessary for billing (or a subset of the forgoing).

The information required for billing depends on the selected payment method and may thereby include the credit card number, card verification code, account number, billing zip code or any other information required in connection with the payment methods that you have selected.

We collect your zip code for the purpose of examination of fraudulent actions, calculation of tax, transaction processing and support. We do not transfer your zip code for advertising purposes or purposes external to the transaction to providers of the Products offered through our Store, third party providers or suppliers. We also do not sell your zip code in connection with other information, do not connect it with data sets external to the transaction and do not use it ourselves for advertising purposes.

If you fill out any of the contact forms of the Site or the Store, we collect your name, company, country, email address, the description of your support request and any other information you choose to provide.

When you contact us by email or telephone or if you are using any of the email addresses or telephone numbers provided on the Site, we collect any Personal Information you may provide to us voluntarily in connection with this communication.

If you provide feedback to us, we may use and disclose such feedback for any purpose provided we do not associate such feedback with your Personal Information. We will collect any information contained in such feedback and will treat the Personal Information in it in accordance with this Privacy Policy.

We will send you strictly service-related announcements (such as, but not limited to, notices related to your purchase of Products, any updates to our General Terms and Conditions of Sale, or Privacy Policy) when we believe it is necessary to do so. You may not opt-out of these communications, which are not promotional in nature.

Within the scope of cleverbridge's personalized services, your data will, subject to your consent, be used for advertising, market research and tailoring electronic services. Unsubscribe instructions will accompany each newsletter or promotional communication you receive from us. In addition you can withdraw your consent at any time in the future. For more information see: Review and Correction of Personal Information.

Automatic Data Collection and Anonymous Information

We receive and store certain types of information whenever you interact with us. This automatic exchange of data between your browser and our server upon accessing our pages informs us of which browser you are using, the date and time of your visit, the name of your Internet Service Provider (ISP), the web site you are using to visit us and which of our web sites you are visiting.

The information we collect automatically is called "Anonymous Information". Anonymous Information means information that is not associated with or linked to your Personal Information. Thus Anonymous Information does not permit the identification of individual persons.

We may use this Anonymous Information for internal purposes, such as maintaining our operating ability, preventing fraudulent access to our ordering service or analyzing usage patterns so that we may enhance our Site. We also reserve the right to use and disclose any Anonymous Information at our discretion, although you will remain anonymous as an individual user.

We automatically collect Information through different technologies as described below.

Cookies and Other Tracking Technologies

Our web sites utilize Cookies and tracking technologies. Cookies are small text files that are transferred to your computer through your Web browser to enable our systems to recognize your browser and your personal preferences or login information (if any). There are two different types of Cookies:

Session Cookies which expire once you close your Web browser and

persistent Cookies which stay on your computer until you delete them.

cleverbridge may use both. Since the foregoing information may be collected when you are signed into the Store, this information may be associated by us with the Personal Information that we have collected from you.

However, using cleverbridge systems does not require that Cookies be accepted. Most browsers accept Cookies automatically. You can stop Cookies from being saved to your hard drive by selecting "do not accept cookies" in your browser settings. Refer to your browser's manual for more information on how this can be done individually. In addition, you can delete Cookies that have already been saved on your computer at any time. While you still be able to use the Store and order Products if you disable Cookies in your browser, certain parts of the Store may not function as effectively or it may even lead to limitations in the functionality of our services.

Tracking technologies may record information such as, but not limited to, Internet domain and host names, browser software and operating system types; click-stream patterns; and dates and times that our site is accessed.

Google Analytics

Our web site uses Google Analytics, a web analytics service provided by Google Inc. ("Google"). Google uses Cookies to help analyze the use of the web site. The information generated by the Cookie about your use of the Site is sent to a Google server in the United States and stored there. Please note, that your IP address will be truncated by our systems before sending the data to a Google server. Thereby you will remain anonymous as an individual user.

Google will use this information to evaluate your use of the Site, compile reports on Site activity and provide other Site activity and internet related services. In addition, Google may also transfer this information to third parties if required by law or if third parties process the information on Google's behalf.

By using this Site, you consent to the processing of data about you by Google in the manner described and for the aforementioned purpose. More information about Google Analytics can be found here.

As Google uses Cookies you can reset your browser to refuse all cookies or to indicate when a cookie is being sent as described in the Cookies section of this Privacy Policy.

Personal Information from Other Sources

We may receive Personal Information about you from other sources like telephone or fax, or from third parties that provide services for us in connection with the Store/Sites. We may add this information to the data we have already collected from you via the Store/Site.

Disclosure of Personal Information

Except as otherwise stated in this Privacy Policy, we do not use or share your Personal Information with Third Parties, unless you ask or authorize us to do so. We will not sell or rent any of your Personal Information to Third Parties for their marketing purposes and only shares your personal information with third parties as described below.

Provider of the Products from a Store

We will provide Personal Information to the Providers of the Products offered through the Store to enable them to provide you with the Products, to register you as authorized users, to provide you with support and updates, and for similar purposes. Please note that Providers use your Personal Information according to their own Privacy Policy that may differ from this Privacy Policy. If you want to know how Providers collect, use, and disclose Personal Information, please visit their website and review their Privacy Policy.

Third Party Service Providers and Suppliers

We may provide your Personal Information to third party service providers and suppliers who work on behalf of or with us to provide you with the Store and Products, related customer support, and to help us communicate with customers and to operate the Site and Store. Examples of such services include communicating with you via email, processing payment transactions, shipping Products, screening Orders for fraudulent activities, remain compliant with applicable laws, and/or providing customer service or fulfillment services for us. However, these service provider and suppliers do not have any independent right to use this information except as to help us providing the Store, its related processes and the Products.

In order to avoid defaults on payment, we reserve the right to obtain information on your creditworthiness from third parties for certain payment methods (direct debit, purchase order), e.g. based on mathematic-statistical processes. In this event, you will be explicitly informed during the ordering process.

In case of non-redemption of a direct debit transaction that is not caused by a revocation through the account holder, we reserve the right to report your account information (account number, bank routing number) to a third party that saves these facts in a lock file and send them to other companies that are affiliated with the direct debit procedure. The blocking shall be deleted after the amount invoiced has been settled.

Law Enforcement, Governmental Authorities and Agencies

We may disclose in formation we have collected from and about you (including Personal Information) if we believe in good faith that such disclosure is necessary to

comply with relevant laws or to respond to subpoenas or warrants served on us;

to enforce our General Terms and Conditions of Sale and Privacy Policy; or

to protect and defend the rights or property of us, the visitors of the Store and Site and our customers, or third parties.

For tax-exempted orders originating in certain EU countries, your address information may be passed on to the responsible tax authorities in order to establish that your VAT identification number (VAT-ID) is correct.

Business Transition

In the event cleverbridge goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your Personal Information will likely be among the assets transferred. You acknowledge that such transfers may occur, and that any acquirer of cleverbridge or its assets may continue to use your Personal Information as set forth in this Privacy Policy. You hereby consent to cleverbridge sharing your Personal Information under the above circumstances.

Export and Processing of Personal Information in Countries Outside of the European Economic Community

We hereby state that, for the purposes of processing your order, your data may be transferred to our subsidiary based in the United States and/or to product providers through us and who are based outside the European Economic community in countries that, to date, generally do not have a data privacy level that is recognized as being congruent to the European Union.

Please note, that our subsidiary participates in the Safe Harbor program developed by the US Department of Commerce and the European Union. The cleverbridge, Inc. is certified to adhere to the Safe Harbor Privacy Principles agreed upon by the United States and the EU.

Data Security and Confidentiality

In order to maintain the highest level of customer and client protection, we adhere to the applicable industry rules and regulations. Thus, we maintain commercially reasonable and appropriate physical, electronic, and managerial measures and procedures to safeguard and secure your Personal Information during data collection, transmission and storage. Your data are only accessible by authorized persons who are familiar with cleverbridge's data privacy policies. However, no company, including cleverbridge, can fully eliminate security risks associated with Personal Information.

Secure Socket Layer

All access to the online shop's ordering pages at cleverbridge is granted using Secure Sockets Layer (SSL) technology, which encrypts Personal Information you provide during the ordering process. Thereby confidential data is protected against being intercepted by third parties and your Personal Information is transferred through this secure channel. To ensure this level of security, our systems use a certificate in keeping with common practice in e-commerce. This certificate is issued by a trusted security provider. All standard web browsers support this technology and accept the certificates from trusted providers automatically. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security, you can contact us at privacy(at)cleverbridge.com.

Credit Card Data

cleverbridge maintains full compliance with PCI DSS (Payment Card Industry Data Security Standard) to enhance payment card data security and provide a secure e-commerce environment for our customers. The PCI DSS standard lays out requirements for network architecture, software development, security management and other critical proactive measures to ensure the safety of payment card transactions. Each year a Qualified Security Assessor thoroughly examines the processes within cleverbridge to make sure we adhere to the strict PCI regulations.

Thus, we reveal only the last four digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate payment processor during order processing. Due to the Requirements of the PCI DSS, this transfer is secured using SSL.

Review and Correction of Personal Information

In order to review, correct, block or delete your stored Personal Information, please send us a brief request in writing, either via post or email (see below). In the event that, despite our efforts to maintain data correct and up-to-date, false information has been saved, then we will change it upon your request. You will normally receive a response to your request from us within thirty (30) days.

For more information on whether we store Personal Information about you and what this data is or other data privacy topics, please contact our data privacy agent in writing:

Data Retention:

cleverbridge will retain personal data we process on behalf of our clients for as long as needed to provide services. cleverbridge will retain and use this Personal Information as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.

Please note:

Upon full consummation of your contractual relationship with cleverbridge, your data (including Personal Information) will, upon your request, be blocked at the internal cleverbridge systems from further processing and deleted after completion of the mandatory legal storage periods.

You understand that any deletion of your Personal Information extends only to the data related to you as a person. cleverbridge will not have any liability whatsoever to you for any termination of your Account or related deletion of your Personal Information or data.

When we delete Personal Information that we have collected from or about you, it will be deleted from our active databases but may remain in our archives.

Notice to California Residents

If you would like to know

the categories of Personal Information about you that we disclosed in the prior calendar year to Providers for the purposes of the Provider's marketing and/or

the names and addresses of such Providers, please contact us. In order to do so, please send us a brief request via email to privacy(at)cleverbridge.com.

Please note that we are required to respond to one request per California resident each year, and we are not required to respond to requests made by means other than through email.

Links to Other Web Sites

The Site may contain links to other web sites that are not owned or controlled by cleverbridge. The provision of such links is for your convenience and does not signify our endorsement of such web sites or location or its contents. We have no control over, do not review and are not responsible for the privacy policies of or content displayed on such other web sites. Please be aware that the terms of our Privacy Policy do not apply to any outside web sites.

Privacy of Minors

In principle, persons under the age of eighteen (18) should not transfer any Personal Information to us without the consent of a parent or legal guardian. We will neither intentionally ask for Personal Information of minors, nor collect or transfer them.

Notice to residents of the United States: We do not intentionally collect or maintain information from those visitors of the Site who are under thirteen (13) years old.

Changes in this Privacy Statement and Previous Versions

This Privacy Statement is a living document. As part of the General Terms and Conditions of Sale, this Privacy Policy is subject to occasional amendment, in accordance with the General Terms and Conditions of Sale. In addition we may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.